ML20196B504
| ML20196B504 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/24/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0261, GDP-98-261, NUDOCS 9812010113 | |
| Download: ML20196B504 (9) | |
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I USEC A Global Energy Company November 24,1998 GDP 98-0261 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No 70-7001 -
Response to Request for Additional Information - Updates to Certification Application I
Dear Dr. Paperiello:
By letter dated June 12,1998 (Reference 1), the NRC requested additional information regarding the appropriatemss of changes made to the certification application under 10 CFR 76.68. In a L
letter dated July 13,1998 (Reference 2), USEC responded to questions 1.2,3,5,6,7,8,9,12, and 13 from the NRC's June 12,1998 letter.
i USEC's responses to questions 4,10, and 11 from the NRC's June 12,1998 letter are provided in Enclosure 1. Also included in Enclosure 1 are revised responses to questions 7 and 8.
j This letter completes USEC's responses to the June 12, 1998 NRC request for additional information. Should you have any questions related to this subject, please contact Steve Routh at (301) 564-3251. Enclosure 2 identifies new commitment contained in this submittal.
Sincerely, 1
S.D.Ga%g, Steven A. Toe'lle l
Nuclear Regulatory Assurance and Policy Manager 7, oh N\\
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9812010113 981124 4
PDR ADOCK 07007001 C
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6903 Roddedge Drive. Bethesda. MD 20E17-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com
.. Offices in 1.ivermore CA Paducah, KY Portsmouth. OH Washington, DC NOV25 m
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Dr. Carl J. Paperiello November 24,1998
. GDP 98-0261, Page 2 l
References:
1.
Letter from Merri Horn (NRC) to Mr. James H. Miller (USEC), "Paducah j
Updates to Certification Application," June 12,1998.
i 2.
Letter from Steven A. Toelle (USEC) to Dr. Malcolm R. Knapp (NRC),
"Paducah Gaseous Diffusion Plant (PGDP), Docket No. 70-7001, Response to Request for AdditionalInfonnation - Updates to Certifimtion Application,"
Letter No. GDP 98-0134, July 13,1998.
Enclosures:
1.
United States Enrichment Corporation, Paducah Gaseous Diffusion Plant, Docket No. 70-7001, Response to June 12,1998 NRC Request for Additional Information 2.
Commitment!. Contained in This Submittal cc:
Mr. Robert C. Pierson, NRC HQ NRC Region III Office.
NRC Resident inspector - PORTS NRC Resident Inspector-PGDP J
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Enclosure GDP 98-0261 Page 1 of 6 United States Enrichment Corporation Paducah Gaseous Diffusion Plant Docket No. 70-7001 Response to June 12,1998 NRC Request for Additional Information j
l 4.
On page 3.11-1, Rev. 24, you have added the statement that the laboratory may provide analytical services to offsite customers under contract agreements. Please explain the basis for adding this statement. Paducah's authorizations in chapter i do not include conducting analytical services to offsite customers. It does provide for analysis of DOE environmental sampies to support the site remediation activities.
USEC Resoonse j
The statement was added to SAR Section 3.11 to reflect the fact that PGDP has historically provided analytical analysis to offsite customers. The analytical work for offsite customers includes potential laboratory work on non-radionuclide samples and does not include work outside the possession limits or authorized uses identified in SAR Chapter 1. It is PGDP's intent to continue to provide these non-radionuclide analytical services for offsite customers. Because these services do not involve NRC regolated materials and substances, the radionuclide possession limits and authorized uses identified in SAR Chapter 1 are not impacted.
SAR Section 3.11 has been changed to delete the identification of analytical services for offsite customers because this work does not involve NRC regulated materials and substances.
Aeolication Revision The first paragraph of SAR Section 3.11 has been changed to read as follows:
The primary missions of the Laboratory are to supply quality analytical services to the site; provide process support for existing equipment and systems; and provide technology recommendations for new equipment and system requirements. In additiva, ilic la'uviaiviy nucy givv>Jc analyiival 3cnivc3 iv viT3;ic cu3iv.ucis uudci cvuin avi ag cciucui3. Analyiival scnivc3 aic iailvicd iv vusivinci uccus. A varied capability of personnel expertise and eqaipment is maintained.
Enclosure GDP 98-0261 Page 2 of 6 7.
In Table 5.1-7 (page 5.1-22) and references on page 5.1-11, Rev 21, explain why you have changed all references to the frequency of analysis to frequency of sampling. The frequency of analysis and the frequency of sampling are not interchangeable, in fact sampling often occurs more frequently than analysis when composite samples are utilized. The change to sampling imtead of analysis actually makes some of the information in the table incorrect. The flow proporticaal continuous samplers are not sampled on a weekly, monthly or quarterly basis; this is the frequency for analysis of the composite samples that are collected continuously. The analysis frequency is an important piece ofinformation for the monitoring program and should be included in Chapter 5.1.
USEC 2esconse Prior to the revision in question, SAR Table 5.1-7 and the text in SAR Section 5.1 specified the frequency for sample election and analysis. The table was revised to specify the frequencies applied to the sample collection interval and removed the frequency oflaboratory analysis. Analysis of samples at the exact frequency of submittal is not required due to the nature of the program described in SAR. ection 5.1.
The reitine outfall samples are used for long-term tracking and trending of efUuents for the purpose ofidentifying plant changes resulting in efiluent characteristic changes as described in SAR Section 5.1. The samples are not used for real-time process control purposes. The control of efDuents is maintained at the origination point per SAR Section 5.1.1.2 and the Radioactive Waste Management Plan.
Due to the length of the ditches and the low flow rate in many of the ditches, there is ofien a lengthy period between the time a release from a building eccurs and the time the release reaches the sampling point. In addition, the continuous composite samplers may be subsampled weekly, monthly, or quarterly per SAR Table 5.1-7 and grab samples are obtained at infrequent intervals. Individual releases cannot be tracked and process control cannot be accomplished using these techniques.
Due to the nature of the sampling program, PGDP does not expect to identify individual releases through the program described in SAR Section 5.1. Should a spill or other release occur, as identified by the corrective action process or other notification system, special samples are obtained and analysis is expedited. All spills are required, by procedure, to be reported to the Plant Shift Superintendent (PSS). Environmental Compliance is notified of all such reports.
Elevated levels of radionuclides in individual samples and trends from the results of multiple samples may trigger investigations per SAR Table 5.1-4 to identify plant changes resulting in changes in effluent characteristics. While timely analysis is necessary, it is not required that samples be analyzed at the same frequency they are obtained for the purpose of tracking and trending because the purpose I...
Enclosure GDP 98-0261 Page 3 of 6 of the program is long-term. Sampling in response to actual or suspected releases does require analysis at the same frequency as sampling. Such targeted sampling is not described in SAR Section 5.1.
The term " continuous sampling" includes both noninterrupted sampling and repetitive sequential collection of small samples obtained automatically at intervals shon enough to yield a representative sample for the entire sampling period. SAR Table 5.1-7 identifies Outfalls 001, 008, 009, and either 010 or 011 as being continuously sampled. The weeldy, monthly, and quarterly intervals penain to the schedule for the submittal of subsamples for analysis.
Aeolication Revision l
I The last paragraph of SAR Section 5.1.2 will be changed to read as follows:
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Sampling frequencies for various environmental samples are specified in this section.
l These frequencies are the frequencies with which individual samples are obtained or l
composites prepared from individual samples. Further compositing of samples l
beyond that established in this section is not performed. Each sample is analyzed in l
a timely manner to support both the demonstration of compliance with 10 CFR 20 and l
long-term trending of environmental data.
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Enclosure GDP 98-0261 Page 4 of 6 8.
In Table 5.1-9 (page 5.1-24) and reference on page 5.1-12, Rev. 21, explain why you have deleted the analysis frequency. Again the analysis frequency is an important piece ofinformation for the monitoring program and should be included in Chapter 5.1.
USEC RespDass Prior to the revision in question, SAR Table 5.1-9 specified the frequency for the collection and analysis of samples. The table was revised to specify the frequencies applied to the collection interval and removed the frequency oflaboratory analysis. Analysis of samples at the exact frequency of submittal is not required due to the nature of the program described in SAR Section 5.1.
Process control of emissions from the C-310 Purge and Vent Stack and the C-335 UF /R-ll4 6
Separation System is accomplished through the use of on-line, real-time monitors and other process instrumentation. The sampling programs described in SAR Section 5.1 are for the purpose of quantifying emissions and for long-term tracking and trending ofemission characteristics. The results l
of these programs cannot be used for process control as the analysis of samples takes a minimum of several hours.
Due to the nature of the sampling program, PGDP does not expect to identify individual releases through the program described in SAR Section 5.1. Should a release occur, as identified by the l-corrective action process or other notification system, special samples are obtained and analysis is l
expedited. All releases are required, by procedure, to be reported to the PSS. Environmental Compliance is notified of all such reports.
l Elevated levels of radionuclides in individual samples and trends from the results of multiple samples may trigger investigations per SAR Table 5.1-1 to identify plant changes resulting in the changes in emission characteristics. While timely analysis is necessary, it is not required that samples be analyzed at the same frequency they are obtained for the purpose of tracking and trending because the purpose of the program is long-term. Sampling in response to actual or suspected releases does require i
analysis at the same frequency as sampling. Such targeted sampling is not described in SAR Section i
5.1.
Aeolication Revision l
I See the response to Question 7.
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Enclosure GDP 98-0261 j
Page 5 of 6 10.
On page 6.9-2, Rev. 24, explain the basis for changing when an investigation will be conducted for an event. Investigations were conducted for each reportable event and is now only conducted for those events requiring a written report. This change would appear to decrease the effectiveness of the event investigation program. Even when events do not require a written report,it is still important to understand the root cause and to implement corrective actions to prevent recurrence.
USEC Resp 0mc The basis for the change made to Safety Analysis Report (SAR) page 6.9-2 (Rev. 24), was to clarify that 30-day reports were not required to be sent to NRC for notifications made under the reporting criteria of NRC Bulletin 91-01. However, upon further review, USEC has determined that the change did not properly characterize how reportable events, which do not require a written response, are investiga*.ed.
All reportable events, whether or not a followup written report is required, are investigated to determine the corrective actions necessary to prevent recurrence. This investigation is conducted and documented, as required, by the plant corrective action process. The magnitude of this investigation is dependent upon the significance and complexity of the reportable event. This may range from the i
assignment of an event investigation team or may be as simple as a one person investigation. In all cases, the corrective action process investigation results in the development of corrective actions to prevent recurrence, which are approved by management. Therefore, the effectiveness of the event investigation program has not been decreased.
SAR Sections 6.9.4,6.9.5, and 6.9.6 were revised in Revision 31 (November 6,1998) to clarify how reportable events are investigated.
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Enclosure GDP 98-0261 Page 6 of 6 11.
On page 6.9-2, Rev. 24, explain the basis for changing when corrective actions will be developed for an event. Corrective actions were developed for each event or condition which required NRC notification and now only developed for those events or conditions requiring written reports. This change would appear to decrease the effectiveness of the corrective action program. See also question 10.
USEC Resoonse Refer to the response to the response to Question 10.
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a GDP 98-0261 Page1 ofI Commitments Contained in This Submittal 1.
The last paragraph of S AR Section 5.1.2 will be changed to read as follows:
Sampling frequencies for various environmental samples are specified in this section.
These frequencies are the frequencies with which individual samples are obtained or l
composites prepared from individual samples. Further compositing of samples beyond that established in this section is not performed. Each sample is analyzed in a timely manner to support both the demonstration ofcompliance with 10 CFR 20 and long-term trending of environmental data.
This application change will be completed by January 15,1999.
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